Kenne Michael 
Sam Bankman-Fried’s attorneys plan to present an expert witness to contradict the testimony of former Alameda Research CEO Caroline Ellison and other witnesses regarding the extent of financial ties between FTX and the trading firm.
In a letter dated October 23 to New York District Judge Lewis Kaplan, Bankman-Fried’s attorneys stated that PF2 Securities consultant Joseph Pimbley would depose on behalf of the former FTX CEO.
The letter states that Pimbley will testify, based on FTX database information, that Alameda’s line of credit with FTX “fluctuated between approximately $1 billion and $3 billion” between October 2021 and September 2022 and decreased in June 2022 to establish a definitive timeline for the line of credit.
Pimbley will also testify that the majority of non-FTX and non-Alameda user balances are in U.S. dollars, Bitcoin, Ether, and Tether and that over 75% of non-FTX and Alameda user balances “arise from accounts that have spot margin enabled, spot margin lending enabled, or show futures activity,” which could provide context for the testimony of former FTX executives.
In addition, the testimony will refute Ellison, FTX co-founder Gary Wang, former FTX engineering director Nishad Singh, and former FTX employee Adam Yedidia’s testimony regarding Alameda’s line of credit and FTX customer use of margin trading.
Pimbley will refute Ellison’s testimony that Alameda had “an essentially unlimited line of credit on FTX” and Wang’s testimony that the company had borrowed “around $3 billion” from the credit line.
Pimbley’s 54-page disclosure contains a variety of charts, spreadsheet extracts, diagrams, and database queries extracted from FTX’s Amazon Web Services database pertaining to FTX’s line of credit with Alameda between October 2021 and November 2022.
Pimbley is paid $720 per hour plus expenses for his services, but he has stated that he has “no financial interest in the outcome of this case.”
He was one of seven expert witnesses initially proposed by Bankman-Fried’s legal team; however, Judge Kaplan barred them from testifying but permitted future testimony if they responded to and clarified government witness testimony.